Privacy Notice

• When you give it to us directly. For example, personal information that you submit through our website by making a donation, signing up for newsletters, events or personal information that you give to us when you set up a regular direct debit gift or communicate with us by email, phone, letter or complete an application form.
• When we obtain it indirectly. For example, your personal information may be shared with us by third parties including other military or military-related charities; Army Units; family or friends who have suggested that you might require our services; websites like JustGiving offering fundraising services; an employee of ours that has given your details as an emergency contact or referee; sub-contractors in delivery of our services; or employment agencies.  To the extent that we have not done so already, we (or they) will notify you when we receive information about you from them and tell you how and why we intend to use that information.
• When it is available publicly. Your personal information may be published on publicly available sources including where you have made your contact information available on your organisation’s website and we use this to contact you. Our use of publicly available personal data complies with the principles set out in the UK GDPR.
• When you visit our website. When you visit our website, we use essential cookies so that the website functions correctly. We, like all organisations, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer. With your consent we place functional, performance and targeting cookies. Please see our Cookie Policy for more. To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/. The legal basis for the processing of personal data in this context are Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents. The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

There are many different data processing activities across the Army Benevolent Fund. We will only ever capture the minimum amount of information that we need for the particular reason we are processing your data. The most commonly collected personal information are your name and contact details including postal address, telephone number and email address and, where applicable, your social media profile. We may also process the following:

• Your date of birth and gender
• Financial information you provide where you make a payment, such as bank details and/or credit/debit card details although we don’t store credit or debit card details.
• Information as to whether you are a taxpayer so that we can claim Gift Aid
• National identifiers such as an Army service number or National Insurance number
• Social relationship data relating to family or social relationships
• Health data and other special category data
• Details of work history and qualifications
• Photographic and CCTV data
• And in some, but fewer cases, information about:

• • Life history – brief or detailed descriptions of significant life events that could identify you
  • Socio-demographic data – for example, information about your role in society
  • Preference data – for example, your likes and dislikes

Certain categories of personal information are regarded by the law as more sensitive than others.  This is known as ‘special category’ or ‘sensitive personal data’ and covers things like information about your health, ethnic origin, religious beliefs, political opinions or any genetic or biometric data that is used to identify you.

We do not usually collect ‘sensitive personal data’ about our supporters unless there is a clear reason for doing so, such as participation in a running or cycling event or similar fundraising event where we need this information to ensure that we provide appropriate facilities or medical support to enable you to safely participate. We may also collect sensitive personal data if you make the information public or if you tell us about your experiences, for example, if you agree to act as a case study or ambassador for us.

To be within the scope of UK GDPR, this personal data must be recorded in a Charity filing system, or we have an intention of recording it in a filing system. Any personal information you tell us that we do not file, or do not intend to file, for example personal information you may tell us during a telephone conversation that we do not record in any way, is outside the material scope of UK GDPR.

Your personal data is required to enable the Army Benevolent Fund to achieve its aims and objectives as a charity. Your personal information, however provided to us, will be used for specific, explicit, and legitimate purposes which include:

• to provide you with support or information you have requested;
• to provide services to our beneficiaries;
• to provide further information about our work, services, activities or products (where you have provided your consent to receive such information; or you would have a reasonable expectation to receive such information)
• to process your donations;
• to answer your questions/ requests and communicate with you in general;
• to manage relationships with our supporters and beneficiaries;
• to ensure your safety when you visit our offices
• to further our charitable aims in general, including for fundraising activities;
• to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
• to report on the impact and effectiveness of our work;
• to run/administer our website, keep it safe and secure and ensure that content is presented in the most effective manner for you and for your device;
• for administrative purposes, for example, we may contact you regarding a donation you have made, including in relation to Gift Aid or an event you have registered for;
• to process your application for a job or volunteer role with us;
• to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
• for the prevention of fraud or misuse of services; and/or
• for the establishment, defence and/or enforcement of legal claims.

The UK GDPR requires us to rely on a lawful basis for each data processing activity undertaken with your personal data including those set out in the previous section. These legal bases are:

• Consent.  Where you have provided your consent for our use of your personal information in a certain way (for example, where you have provided your consent for us to use your personal information to send you fundraising material by email, or to send you our newsletter).
• Contractual obligation.  Where it is necessary for us to process your personal information in order to perform a contract to which you are a party, or to take steps prior to you entering a contract, for example where you apply for a role at the Army Benevolent Fund.
• Legal obligation.  Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. For example, this might be where we have a legal obligation to share personal information with HMRC for Gift Aid claims or tax calculations; or process your data when you have exercised your data protection rights.
• Vital interests.  Where it is in your, or someone else’s vital interests. For example, in the case of a medical emergency suffered by an individual that needs to be reported by us to the emergency services.
• Public Interest.  Where it is necessary to perform a task carried out in the public interest.
• Legitimate interests.  Where applicable law allows us to collect and use personal information on the condition that to do so is necessary for our legitimate interests and the use of your personal information is fair, balanced, and does not unduly impact your rights. In broad terms, our “legitimate interests” means the interests of running the Charity as a charitable entity, and pursuing our aims and ideals; for example:

• the administrative activities of providing support to our beneficiaries,
• taking donations,acknowledging your kind donations,
• administering events,
• receiving applications forms,
• passing data between the Army Benevolent Fund and Soldiers Trading,producing anonymous statistical reporting,
• ensuring the contact details we have for you remain accurate,
• In addition, where we process special categories of data an additional condition of processing is established and documented as required by the UK GDPR and DPA 2018.

We commit to building open and honest relationships with supporters of the Army Benevolent Fund. Transparency and privacy are key to our approach. To help us understand our existing donors better we undertake in-house research which may involve gathering information about you from publicly available sources, for example, Companies House, property registers, 192 directory, The Times Online and Who’s Who; and segment donor information based on characteristics such as the number and value of donations. We may from time to time engage specialist agencies to gather information about you from similar publicly available sources and create a profile about you and your interests.

This is often called “wealth profiling”. This analysis and research helps us to understand the background of our supporters so that we can make appropriate requests to those who may be willing and able to give more than they already do, enabling us to raise funds and help beneficiaries sooner and more cost-effectively. You will always have the right of opting out of this processing (see below). We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. We also use publicly available sources to carry out due diligence on donors, to meet money laundering regulations, and ensure gifts to the Charity are in line with the Charity’s Anti-Fraud and Anti-Bribery & Corruption Policy.

This research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you.

If you would prefer us not to use your personal information for supporter research, please let us know by contacting us at [email protected].

We do sometimes need to share your personal information with other third parties in order to effectively provide our services, however we will never sell or rent your personal information for marketing purposes.  Third parties we may share data with include, inter alia:

• Army Units
• Professional services including solicitors
• Parties who assist the Charity in the administration of beneficiary enquiries
• Fundraising event organisations
• IT providers and cloud storage providers
• Regulatory authorities, such as tax authorities
• Order and postal donation fulfilment organisations
• Mailing house providers
• Payroll Giving providers
• Content management system providers
• Organisations specialising in processing financial transactions and direct debits
• Organisations specialising in administering fundraising lotteries and online tribute pages
• Organisations specialising in advertisements to appear in social media newsfeeds

n.b. In rare circumstances, where we identify an individual as being at risk of harm to either themselves or others, or has other safeguarding needs, we may need to pass personal data to local authorities, medical professionals or emergency services.

The Army Benevolent Fund has an online presence through the following third-party social media platforms.

• Facebook
• Instagram
• LinkedIn
• YouTube
• Twitter

Where supporters engage with our posts or publish content relevant to our Charity, we may like the posts, follow them, reply or write to them.  We may provide Facebook with email addresses of those who have signed up to receive newsletters or other fundraising information in order to allow our fundraising advertisements to appear in your newsfeed and the newsfeed of others.  Facebook only uses your email address for this purpose. This should not disrupt your experience of using Facebook, but if you would like to opt out of this activity you can do so by emailing [email protected].

You can find Facebook’s privacy policy here which also includes privacy details for Instagram.  Please be aware that we cannot remove Facebook ‘likes’ and any comments you post on third party social media platforms will be seen by other users.

We want our social media presence to be a healthy environment for discussion.  Our communications team moderate comments on social media accounts to protect those who view them. We will challenge, rather than delete, inaccurate comments or data, and remove anything that is discriminatory or unlawful.

If you have a complaint or comment about how we moderate social media, please contact us at [email protected].

When you use our secure online donation function to sign up for a one off or regular donation you will be directed to a specialist payment services provider who will receive your financial information to process the transaction. We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.  We will also ensure that card details are handled securely under Payment Card Industry (PCI) Data Security Standards.

If you provide your card details to make a donation or payment by phone we will never store your credit or debit card details following the completion of your transaction.  Please do not send an email containing any credit or debit card details, since it will be immediately deleted and no payment will be taken.  If this happens, we’ll let you know.

The Army Benevolent Fund is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information. Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers with features enacted to prevent unauthorised access.

We conduct supplier audits with our main data processors to ensure their information security system is robust and UK GDPR compliance is in place to ensure the safety and security of personal data we share with them.

In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, personal data that we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it in the different periods as shown below:

There are circumstances whereby data may be disposed of and/or anonymised before the maximum retention period. These are:

• your personal information is no longer required in connection with the purpose for which it was collected for.
• we are no longer lawfully entitled to process it, or
• you validly exercise your right of erasure and we delete/fully anonymise the data.

We may need to keep your personal data for statutory purposes, for example, gift aid declarations.

If you request to receive no further contact from us we have a legal obligation to maintain a small amount of data on our suppression list. This will comprise of your name and contact details in order to comply with your request and ensure we avoid sending you unwanted materials in the future.

When we process your personal data, you have the right to:

• Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that information. If we are satisfied that you have a right to see this personal information, and we can confirm your identity, we will provide you with this personal information.
• Request that we delete the personal information we hold about you, as far as we are legally required to do so.
• Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
• Object to the processing of your personal information where we:

• • process on the basis of legitimate interests;
  • use the personal information for direct marketing; or
  • use the personal information for statistical purposes.

• Ask for the provision of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us:

• • in reliance on your consent; or
  • because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means
• Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.

You are not required to pay any charge for exercising your rights; if you make a request, we will normally have one month to respond to you.  If you decide you do not want to receive any further emails from us, please tell us and we will remove you from the mailing list. At any point you can report any concerns to us or request to unsubscribe from our mailings by contacting us using the contact details listed in the section entitled “Who we are”.  You also have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113